PHA Project to LIVE status and Case Studies on Deviations
Transcript of PHA Project to LIVE status and Case Studies on Deviations
PHA Project to LIVE status and Case Studies on Deviations
Geetali Thakur Head – HSE Deccan Fine Chemicals (I) Pvt Ltd, Goa, India
Content
PHA at project stage
Commissioning pre startup review
Managing changes
Case studies deviations
Disclaimer
The statement, opinion, observations and predictions are solely that of the presenter and do notnecessarily represent official policy or position of Deccan Fine Chemicals I Pvt Ltd (DFCIPL).
The opinion, information presented here in are of the presenter and DFCIPL attracts no liabilityto the completeness of this information.
Case studies used in this webinar are not real incidents that have occurred anywhere in theindustry and are solely presented for academic purpose of knowledge gain.
Manufacture, Storage and Import of Hazardous Chemicals Rules,1989 (MSIHC)
07/10/2020 PHA Slide 5
Schedule 8 – Information to be furnished in a Safety Report
Process Hazard Analysis
What
• Set of organized and systematic assessments of the potential hazards associated with an industrial process
Why
• To analysepotential causes and consequences of major scenarios.
• Confirm controls
When
• Pre project
• Post commissioning
• Revalidation
• Prior to decommissioning
Explore Q1 – Common Hazards:
Fire, explosion, run away reaction : Industry Best practices
Explore Q2 – Blind:
Literature, incidents in industries
Explore Q3 – Hidden:
Relate with other processes, check what controls worked – can we emulate?
Explore Q4 – Unknown:
Chemical Reactive hazards test to be performed?
PHA- A tool to dig the undug
Different Layers of Controls
Engineering ControlAdministrative
ControlBehavioral Control Mitigating Barriers
HazardConsequence
Incident
Weaknesses
Safer DesignInstrumentation in protective systems
Safer proceduresJSAChecklist
Use PPEUse the right toolsUse stop work authority
Emergency Response Plan Fire suppression
PHA at Project Stage
Initial Project Risk Assessment
Pre Hazop Review
Hazop
Review of changes during project and reassessment
Reference: https://www.aiche.org/ccps/resources/tools/risk-analysis-screening-tool-rast-and-chemical-hazard-engineering-fundamentals-chef
Commissioning pre startup review – typical checks
Updated Process Hazard Information
PHA residual actions on track
All statutory approvals obtained
P&ID check – actual vs planned
Cleaning validations
Isolation checks for multi product
SIS system loop check and test
Software loops checked
Software interlocks tested
Mitigative measures trials as applicable
Emergency response preparedness
Safe systems of work
Managing Changes – MOC
MOC Implementation
Develop written procedures for managing change
Implement MOC Procedure
Address the technical basis for each change
Evaluate potential safety and health impacts for each change
Control the duration of the change (if temporary)
Address the need for “emergency” changes
Define/implement requirements for authorizing changes to be made
Appropriately inform and train affected employees and contractors before changes occur
Update any process safety information affected by the change
Update any procedures(including safe work practices) affected by the change
MoC and relevant documentation and updates
Sr. No Change Is it a change? Important documents (not restricted to)
1 SS reactor changed to MSGL same capacity
Yes MoC Compatibility chartP&IDHazopMoSCE (Safety critical equipment)
2 Change of Utility from one variant to another
Yes Chemical CompatibilityMoC Compatibility chartP&IDHazop
3 Implementation of Hazopactions – SRV installation
Yes Relief calculationsP&IDHazop
4 Like to like change of a vessel ? ?
Poll Question -1Is it required to update PHA in case there is change in sampling methodology for a product?
Yes
No
Example: As part of initial PHA No sampling of intermediate was planned. Sampling planned afterfirst few batches. This material was shock sensitive. No MOC was raised.
Operator did not know and happen to take out sample, rinse it to ensure no contaminationbefore filling representative sample. The glass bottle could lead to small blast leading to shattersof glass pieces and thus injury.
NaOHScrubber
Scrubbed gas
PumpPump
Scrubber solution
Scrubber solution
Pdt 2
Water Scrubber
Hypo Scrubber
Pdt 3
CASE 1: Common Scrubber – MPP
• Dedicated productYear 1
• Pdt1+Pdt 2 –Compatible off gases Year 2
• Pdt 1+2+3 – New scrubber solution –Toxic explosible gas release
Year 3
Pdt 1
Disclaimer: Case studies used are not actual incidents but have probability of occurrence in industries in case of similar deviations
LEARNINGS
Poll Question -2
Q : Which level of control was missed in this case? Engineering Or Administrative ?
A : It is almost impossible to control vent header mix-up when lined to same source – thus right design was important.
Engineering Control
Administrative Control
Behavioural Control
Mitigating Barriers
Safer DesignInstrumentation in protective systems
Safer proceduresJSAChecklist
Use PPEUse the right toolsUse stop work authority
Emergency Response Plan Fire suppression
Blind not removed
Reactor
Pump
Isolation valve 2
Product storage tank
Cleaning solvent tank
During ShutdownStart Up
ON-OFF valve
Isolation valve 1
Pump Over Pressurization
RMs
CASE 2: Shutdown cleaning
• MSGL vessel inspectionShutdown
• Blind inserted on pdtdischarge line, isolation valve 1 closed
Reactor cleaned
with solvent
Restart checklist followed
• Blind not removed
Pumping started –Material
onset is at NTP
• Blocked discharge – Pump catastrophic failure
Disclaimer: Case studies used are not actual incidents but have probability of occurrence in industries in case of similar deviations
LEARNINGS
Ref: https://blog.lnsresearch.com/why-10-of-your-operations-cause-50-of-your-safety-incidents
Poll Question - 3
Q : Which level of control was missed in this case? Administrative or Engineering?
A : P&ID mark up during shutdown was missed and accordingly P&ID checks pre start up.
Engineering Control
Administrative Control
Behavioural Control
Mitigating Barriers
Emergency Response Plan Fire suppression
Safer DesignInstrumentation in protective systems
Safer proceduresJSAChecklist
Use PPEUse the right toolsUse stop work authority
DayTank
Atmrated Storage Tank
Tanker for unloading
Isolated day tank for repairs
Vent to scrubber
• MSGL vessel inspection
Shutdown of Pdt 1
• Like to like change – no MoC
MSGL vessel
replacement
Common vapour
equilibrium line
• VEL isolated -Blocked vent
Tanker unloading
• Consequence–Storage tank pressurization
CASE 3: Replacement of Like to Like
Disclaimer: Case studies used are not actual incidents but have probability of occurrence in industries in case of similar deviations
LEARNINGS
Poll Question- 4
Q: Which level of control was missed in this case: Adminstartive or Engineering?
A : Vent should not have been common
Engineering Control
Administrative Control
Behavioural Control
Mitigating Barriers
Emergency Response Plan Fire suppression
Safer DesignInstrumentation in protective systems
Safer proceduresJSAChecklist
Use PPEUse the right toolsUse stop work authority
Clean gas
Organic layer with Fe
Extractor Distillation Column
Scrubber
DM Water
Municipal Water
Pressure Rise
Reactor
• Scrubber used DM waterPjt PHA
• P&ID not updated. Impact was only on waste stream
Post 1 year –DM water ->
Municipal water
• Waste reduction: Scrubber water reused in next stage extractor post PHA
Post 3 years –Enviro
Improvement pjt
• Organic layer onset of decomposition lowered with higher Fe content
Organic layer transferred for
further distillation
• Potential to pressurize the distillation column
Consequence
CASE 4: P&ID not updated
Disclaimer: Case studies used are not actual incidents but have probability of occurrence in industries in case of similar deviations
LEARNINGS
Source: https://www.industrialpackaging.ie/product/ibcs-explosive-zones
• Non conducting Solvent in tanker
PHA @ PjtStage
• Earthing continuity PHA
controls
Procurement team
confirms RM in IBC
• No Pjt MoC/ PHA not Live
RM unloading from IBC
CASE 5: PHA Not updated
• Consequence –Fire!
Disclaimer: Case studies used are not actual incidents but have probability of occurrence in industries in case of similar deviations
Poll Question - 5Can this be a hazard with conducting liquid too?
Yes
No
Yes, there can be as conducting liquid in non conducting vessel travelling long distance which needs to be grounded to dissipate static charges.
Thank You
Geetali Thakur Head – HSE Deccan Fine Chemicals (I) Pvt Ltd, Goa, India
B.E (Chem),MBA(Ops), LFOH(BOHS-UK), [email protected]